Hi there,
Welcome to The Accountability Record. This is a newsletter for the people personally named under SM&CR: the Senior Managers, compliance leads and risk owners who carry individual accountability for what AI does inside a regulated firm.
Last week I shared the Quarterly AI Oversight Pack - the periodic evidence bundle a named individual can put in front of a supervisor to show continuous, not one-off, oversight.
This week I am giving away the Emergent Event Protocol - the pre-agreed playbook for when an AI system does something unforeseen, defining who is accountable, what gets recorded, and what "reasonable steps" looked like before the surprise, not after. Very few have the individual evidence. And the regulator's own guidance on what that evidence should look like is not due until the end of the year, but we have to stand-in with the evidence to demonstrate continuous oversight in the meantime.
BuildMoat builds the engine that produces and maintains these records across every AI system in a firm. Putting the tools in your hands, one at a time, is how we show you the problem is real and the approach works. If the hand-tools are all you ever need, keep them with our compliments. If your AI estate is bigger than a handful of systems, you will know where to find us.
What you're getting this week
This week's free artefact is the Emergent Event Protocol: the pre-agreed playbook for when an AI system behaves in a way no one planned for, setting out who is accountable, what gets recorded, and what happens next. Free, and ready to adapt today.
Why it matters
Reasonable steps is not only about the systems that behave. It includes foreseeability: having a plan for the ways things could go wrong. When a regulator asks whether you anticipated the system behaving unexpectedly and had a response ready, the answer they want to see is one dated before the event, not improvised during it.
The trouble with improvised responses is that they produce improvised evidence. In the moment a system starts declining the wrong customers, or generating something it should not, the people involved are managing the crisis, not recording who decided what. An accountability record written in the aftermath is the weakest kind there is.
What it does
The Protocol sets the triggers for what counts as an emergent event, the escalation chain with named roles, the evidence captured when it fires, the containment options, and the record of who decided what under pressure. Agreed in the calm, it turns a scramble into a sequence, and it keeps the accountability legible afterwards because it was defined beforehand.
A protocol on paper is a start. A protocol that actually fires, captures and timestamps when the event hits is what BuildMoat's engine runs, continuously and tamper-evidently, across your estate. The document shows you the shape. The engine makes it happen when it counts.
→ [Download the Emergent Event Protocol] — free, adapt it to your firm today.
Next week: the Obligation Map, for the gap between your Statement of Responsibilities and what your AI actually does.
Thanks for reading
That's it for this week. If something landed, reply and tell me. If something was wrong, reply and tell me that too. I read every response.
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Regulatory commentary is for informational purposes only and does not constitute legal, compliance, or financial advice. Consult a qualified professional for advice specific to your firm. BuildMoat product mentions are editorially assessed and disclosed where a conflict exists.
Until next week.
